Koreksi Fiskal PPH Terhadap Transfer Pricing Dalam Hubungan Istimewa

The strict competition requires company to fulfill the market demand that always increase from year to year. In supporting its business activity, PT.PSPI is doing the transaction wish the special and common partners. Special treatment that is given by PT. PSPI to their special partner causes value of transfer pricing transaction is not proper. Based on that, PT. PSPI needs correction in income tax fiscal towards the transfer pricing transaction. The purpose of this research is to know about the correction of income tax fiscal towards the transfer pricing transaction in the company. The method used a comparable uncontrolled price to evaluated company’s transfer pricing transaction properly. Comparable data that is used is price comparable data to common partners. Special treatment that is given by PT. PSPI will influence the increasing of underpaid of the income tax.